GNLPSL0012

The north-western corner of the site is in fluvial flood zone 2 & 3 and is also affected by surface water flood risk.

1. Keswick and Intwood Parish Council is strongly opposed to any change in the development boundary to accommodate this (or any other development) included in the list of sites relevant to the Parish.

2. The Parish's opposition to the proposal is backed by Policy 16 of the adopted Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk which identifies Keswick as an "other village" with a defined development boundary allowing only the minimum of infill development to take place without adversely affecting the form and development of the village.

3. The existing development boundary is tightly drawn around the existing built up area along Low Road. The intention is to prevent any further development into the countryside and to protect any future development from the risk of flooding. Moreover, the site in question (which represents a very significant extension of the existing development boundary should it be agreed) has previously been rejected for these reasons.

4. Furthermore, because the site is so far outside the existing designated boundary, any development would be detached from the rest of the village and consequent poor connectivity. The Parish also believes Norfolk County Council Highways has possible concerns about traffic access to the site from the hazardous junction with Low Road and along the single track Mill Lane.

5. Any extension of the existing boundary to include this site would therefore necessitate a significant policy change not only to accommodate the radical redrawing of the boundary, but it would also be clearly damaging and contrary to the objective of retaining the rural nature of the area.

6. Additionally, the site falls within the "River Valley" landscape area which raises further material concerns regarding its suitability for development. Policy DM 4.5 of the South Norfolk Local Plan relates to the protection of Landscape Character and River Valleys stating that: "All development should respect, conserve, and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused". The site also lies adjacent to the grounds of Keswick Old Hall being a Grade II listed building which would arguably be compromised by the development of new housing immediately to the east.

7. One of the eight Strategic Principles of the Site Specific Allocations and Policies Document of the South Norfolk Local Plan is "To avoid allocating land in Flood Zones 2 and 3 (SP4)". It is therefore a material consideration that part of the site falls within the Environment Agency's defined Flood Zones 2 and 3 indicating the highest probability of flooding. It would therefore be counter to both national and local policy to allow built development to take place on this site.

8. The Parish believes that the above considerations fully support its opposition to any future amendment of Keswick's development boundary to accommodate the inclusion of GNLPS L0012.

This response from Keswick and Intwood Parish Council relates to sites:
GNLPS L0012. Up to four houses.
GNLP 2014. Residential and Office building.

1. GNLPS L0012.
1.1 Keswick and Intwood Parish Council (the Parish) is strongly opposed to any change in the development boundary to accommodate this (or any other development) included in the list of sites relevant to the Parish.
1.2 The Parish's opposition to the proposal is backed by Policy 16 of the adopted Joint Core Strategy (JCS) for Broadland, Norwich and South Norfolk which identifies Keswick as an "other village" with a defined development boundary allowing only the minimum of infill development to take place without adversely affecting the form and development of the village.
1.3 The existing development boundary is tightly drawn around the existing built up area along Low Road. The intention is to prevent any further development into the countryside and to protect any future development from the risk of flooding. Moreover, the site in question (which represents a very significant extension of the existing development boundary should it be agreed) has previously been rejected for these reasons.
1.4 Furthermore, because the site is so far outside the existing designated boundary, any development would be detached from the rest of the village and consequent poor connectivity. The Parish also believes Norfolk County Council Highways has possible concerns about traffic access to the site from the hazardous junction with Low Road and along the single track Mill Lane.
1.5 Any extension of the existing boundary to include this site would therefore necessitate a significant policy change not only to accommodate the radical redrawing of the boundary, but it would also be clearly damaging and contrary to the objective of retaining the rural nature of the area.
1.6 Additionally, the site falls within the "River Valley" landscape area which raises further material concerns regarding its suitability for development. Policy DM 4.5 of the South Norfolk Local Plan relates to the protection of Landscape Character and River Valleys stating that: "All development should respect, conserve, and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused". The site also lies adjacent to the grounds of Keswick Old Hall being a Grade II listed building which would arguably be compromised by the development of new housing immediately to the east.
1.7 One of the eight Strategic Principles of the Site Specific Allocations and Policies Document of the South Norfolk Local Plan is "To avoid allocating land in Flood Zones 2 and 3 (SP4)". It is therefore a material consideration that part of the site falls within the Environment Agency's defined Flood Zones 2 and 3 indicating the highest probability of flooding. It would therefore be counter to both national and local policy to allow built development to take place on this site.
1.8 The Parish believes that the above considerations fully support its opposition to any future amendment of Keswick's development boundary to accommodate the inclusion of GNLPS L0012.
2. GNLP 2014.
2.1 The Parish is aware of the number of sites (industrial and other) in the GNLP area with spare capacity and more coming on-stream. This capacity is evidenced by various documents available, typically GNLP Document - Housing and Economic Land Availability Assessment (HELAA) which indicates that in terms of employment land and the delivery of housing, existing sites are sufficient to meet requirements to 2036. The Parish therefore finds it incomprehensible to understand why this and other sites have been included in the Consultation.
2.2 In addition to its opposition to any change in the development boundary, The Parish robustly endorses the comments made in the Consultation Document that the site is unsuitable because:
* although the site has fairly good access to services in Cringleford, it is separated from the built up area by a railway
* constraints include the lack of footpaths
* there are landscape impacts and constraints related to sewage
* there are issues relating to surface water flooding
* listed buildings are located nearby; and
* its proximity to wildlife sites.
2.3 Furthermore, the Parish believes the local road infrastructure is totally inadequate to support this and other agreed (or proposed) developments in the area. The Parish notes the Consultation Document refers to constraints include the lack of footpaths (bullet point 2 above). It is material that this reference is (probably) to the road passing the site which has no footpath and is not suitable for vehicles to easily pass. Already, the Parish has installed warning signs to motorists about horse riders following near miss accidents along this stretch of carriageway.
2.4 Before any further developments are approved in the Keswick and Intwood area (and adjacent parishes), the Parish is convinced that a professional and thoroughly comprehensive study should be undertaken of the local road network and its shortcomings in connection with what is being suggested. The study should make recommendations, based on realistic and confident traffic projections about proposals made, which provide clarity about how planned developments will be serviced by the road network. Moreover, it should demonstrate convincingly how the safety of traffic and (especially) vulnerable road users will be guaranteed. This concern stems from the Parish being of the opinion that on occasions past planning applications may have been supported by road and transport statistics which lacked confidence and integrity.
2.5 The Parish believes that the above considerations fully support its opposition to e the inclusion of GNLP 2014.
3. Conclusion
3.1 The Parish is hopeful that the Consolation will result in the coordination of developments across local areas. The intention must be to bring about the basic physical and organisational structures needed to achieve an enjoyable and agreeable living environment for the local population. Developments cannot be allowed to happen in the haphazard manner which seemingly characterises existing practice.

Keswick and Intwood Parish Council.